Supreme Court of the United States · 1984 · Criminal Procedure
Criminal ProcedureFourth AmendmentExclusionary RuleSearch and SeizureFourth Amendmentindependent sourceexclusionary rulefruit of the poisonous tree
Facts
Task Force agents had probable cause, based on surveillance and information obtained before entry, to believe petitioners were trafficking in cocaine from their apartment. After arresting Segura and taking him to the apartment, agents entered without permission, conducted a limited security check, and then remained inside while a warrant was sought; the warrant was not obtained until about 19 hours later. The warrant was issued on information wholly known before the entry. During the next-day search pursuant to that warrant, agents found cocaine, cash, ammunition, and narcotics records that had not been observed during the initial entry.
Issue
Whether evidence first discovered during a search conducted pursuant to a valid warrant must be suppressed because police had illegally entered and secured the apartment the day before. Also, whether securing the premises from within while a warrant was being obtained constituted an unreasonable seizure of the apartment's contents.
Rule
Where officers have probable cause, temporarily securing a dwelling to preserve the status quo while, in good faith, others are obtaining a warrant is not an unreasonable seizure of the dwelling or its contents for the limited period involved here. Evidence later discovered under a valid search warrant need not be suppressed as fruit of an earlier illegal entry when the warrant was issued wholly on information known before the entry and thus provided an independent source for the evidence.
🔒
See the holding & full analysis
Create a free KwikCourt account to unlock the rest of this brief — and practice the case.
The court's holding and reasoning
Doctrine tests, pitfalls & exam hypotheticals
10 practice questions + 4 AI-graded essays on this case
One of 10 multiple-choice questions for this case. Pick an answer to see why.
Officers in Phoenix developed probable cause over two weeks that Dana Ruiz was storing fentanyl in her townhouse. Without exigent circumstances, they entered unlawfully at night, glanced around, and then stayed inside while another officer prepared a warrant affidavit based entirely on surveillance, informant statements, and controlled buys completed before the entry. The next afternoon, officers executed the warrant and found pills hidden in a basement vent that no one had seen during the initial entry.
Are the pills from the basement vent admissible?
Explanation. The majority held that evidence first discovered during a later search under a valid warrant need not be suppressed when the warrant was issued wholly on information known before the illegal entry. In that situation, the warrant is an independent source, and the later discovery is not the product of exploiting the initial illegality. The contrary choices wrongly treat all later evidence as automatically tainted or rely on a good-faith rationale the majority did not use.